1. Introduction

These Terms and Conditions ("Terms") constitute a legally binding agreement between you ("User," "you," or "your") and Clavis Fintech Solutions Limited ("Clavis," "we," "us," or "our"), a company registered in the United Kingdom (company number 14119103, registered address: 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ).

1.1 Our Role

Clavis provides financial technology services in partnership with Striga Technology OÜ ("Striga"), a regulated virtual asset service provider in Estonia. Our services include both a customized interface to Striga's platform and additional features and services developed by Clavis.

1.2 Service Description

We provide:

• Access to virtual asset and financial services through Striga's platform
• Enhanced user experience and interface customization
• Additional features and services specific to Clavis
• Customer support and service management
• Technical infrastructure and security measures

Your use of the Services is hence additionally subject to the terms of our third-party provider(s) which you must accept before using the Services.

If you wish to use the Services, you must create an account in the Application. Your account must be linked to a valid e-mail address, and you must create a password that you will be using to log in to your account. Requirements of Our third-party service provider(s) apply for account creation and access to Services. 

2. Definitions

• Platform: The combined technology solution including both Striga's infrastructure and Clavis's enhancements
• Account: A unique profile on the Platform enabling secure access to Services via the User Interface.
• Services: All services accessible through our platform, including both Striga's regulated services and Clavis's additional features
• User Interface: The customized application and web interface provided to access the services

• ‍Force Majeure Events: Means any event beyond Clavis Fintech’s reasonable control, including but not limited to flood, extraordinary weather conditions, earthquake, or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications, power failure, or equipment or software malfunction or any other cause beyond Clavis Fintech’s reasonable control (each, a "Force Majeure Event");

3. Fees

We charge the following fees for the Services we provide through the Application:

We collect the above fees through our third-party provider Striga Technology OÜ. We guarantee that we instruct Striga Technology OÜ to debit the fees payable by you from your account in accordance with the pricing applicable to you. We assume sole liability for compensating charged fees to which you have not consented.

Virtual Asset services are provided, and Virtual IBAN issuing and transacting is made available by Striga Technology OÜ (registry code: 16298772), address: Sepapaja 6, Tallinn, Estonia, in accordance with its terms and conditions, that can be found here: https://striga.com/wp-content/uploads/2022/11/T_C_Striga.pdf

The Bitrefill Card is issued, and related payment services are provided by Wallester AS (registry code: 11812881), address F.R. Kreutzwaldi 4, 10120 Tallinn, Estonia, in accordance with its terms and conditions, that can be found here: https://storage.googleapis.com/striga-public-docs/Static%20Partner%20TCs/Striga-Card-T%26Cs-Combined.pdf

4. Prohibited Activities

In accordance with EU regulations and our compliance obligations, the following activities are prohibited:

4.1 Prohibited Business Practices

Business activities that are:

• Prohibited in your EU member state
• Subject to specific regulatory requirements without proper authorization
• In violation of EU sanctions or restrictions

4.2 Fraudulent Activities

You are prohibited from engaging in fraudulent, deceptive, or unauthorized activities while using our services. This includes, but is not limited to:

• Identity Fraud: Creating accounts using false identities, stolen information, or impersonating any individual, entity, or organization.
• Payment Fraud: Using stolen, unauthorized, or counterfeit payment methods to transact or make payments on our platform.
• Misrepresentation: Providing false, misleading, or incomplete information during account registration, verification, or interaction with our services.
• Unauthorized Access: Gaining or attempting to gain unauthorized access to any part of our platform, systems, or data, including other user accounts.
• Manipulative Practices: Engaging in activities designed to exploit vulnerabilities, manipulate transaction outcomes, or bypass platform restrictions.
• Money Laundering: Using our platform to conceal, transfer, or handle funds derived from illegal activities.
• Account Abuse: Selling, transferring, or sharing account access credentials with unauthorized individuals or third parties.

4.3 Consequences of Violation

Violation of any provisions outlined in Section 3 (Prohibited Activities) may result in immediate suspension or termination of your account, freezing of associated funds, and restricted access to our services. Actions taken will depend on the severity and impact of the violation, and you agree to fully cooperate with any investigations conducted by Clavis, Striga, or relevant authorities as required by law.  

5. Data Protection

5.1 Data Processing Roles

In accordance with the General Data Protection Regulation (GDPR):

• Striga acts as the data controller for personal data processed in connection with regulated services.
• Clavis acts as a data processor, processing personal data according to Striga's instructions.
• For additional services provided directly by Clavis, we may act as a separate data controller and will inform you of such instances.

5.2 Data Processing Activities

We process data to:

• Facilitate access to financial services
• Provide customer support
• Enhance user experience
• Ensure platform security
• Comply with legal obligations

5.3 Data Breach Notification

In the event of a data breach that compromises your personal data, we will promptly assess the scope and impact of the breach and take all reasonable steps to mitigate any potential harm. If the breach poses a significant risk to your rights and freedoms, we will notify you without undue delay, following applicable data protection laws, including the GDPR. 

5.4 Data Retention

We retain your data only as long as necessary to fulfill legal, regulatory, and operational requirements, after which it will be securely deleted or anonymized.

6. Dispute Resolution

6.1 Types of Disputes

We categorize disputes as follows:

1. Platform Technical Issues:some text
   • Interface problems
   • Access difficulties
   • Performance issues
   • Feature functionality
2. Service-Related Issues:some text
   • Transaction disputes
   • Account-related concerns
   • Financial service issues
3. General Complaints:some text
   • Customer service
   • Communication issues
   • Feature requests

6.2 Dispute Resolution Process

Step 1: Initial Contact

• Submit your complaint via email to support@ozuma.io
• Include relevant details and documentation
• Receive acknowledgment within 1 business day

Step 2: Investigation & Escalation 

We will:

• Assess the complaint and determine the handling process
• For technical platform issues: aim to resolve within 5 business days
• For regulated services: coordinate with Striga and keep you informed of progress
• Provide regular status updates until resolution. For complex cases, it may take up to 35 business days with periodic notifications. 

If you're unsatisfied with the resolution:

1. Request senior management review
2. Seek independent mediation
3. Contact relevant regulatory authorities

6.3 Financial Services Disputes

For disputes relating to regulated financial services:

• We will coordinate with Striga for a resolution
• Direct you to appropriate regulatory channels
• Assist with documentation and communication

6.4 Alternative Dispute Resolution

You have the right to:

• Seek mediation through approved EU ADR bodies
• Contact relevant financial ombudsman services
• Pursue legal remedies in appropriate courts

7. Service Terms

7.1 Platform Access

We provide:

• Secure access to the platform
• Regular updates and maintenance
• Technical support
• Service monitoring

7.2 Service Availability and Maintenance

     a) Regular Service Availability

•  We strive to maintain 24/7 platform availability
• Some features may be temporarily unavailable during maintenance windows

    b) Scheduled Maintenance

•  Regular maintenance is typically performed during low-traffic periods
•  We will notify you at least 48 hours in advance of scheduled maintenance
•  Scheduled maintenance usually occurs between 02:00-04:00 EET on Sundays
•  Each scheduled maintenance typically lasts no more than 2 hours

    c) Emergency Maintenance

•  May be performed without prior notice to protect platform security or stability
• We will inform users as soon as possible when emergency maintenance begins
• Updates will be provided through email and in-app notifications

    d) Service Interruptions

In case of unplanned downtime, we will:

•  Send notifications for interruptions lasting more than 15 minutes
•  Provide regular progress updates until service is restored
•  Share a post-incident summary for major interruptions

    e) Communication Channels

During any type of maintenance or service interruption, updates will be provided through:

• Email notifications
• In-app alerts
• Our official social media channels

7.3 Force Majeure Event

We are not liable for any failure or delay resulting from Force Majeure Events. During such events, our obligations will be suspended. If the event extends beyond 30 days, either party may terminate the agreement with written notice.

7.4 User Obligations

As a User of our services, you agree to:

• Provide Accurate Information: Ensure all information provided during registration and ongoing use of the platform is true, accurate, and up-to-date.
• Comply with Laws: Use our services in compliance with applicable local, national, and international laws and regulations.
• Maintain Account Security: Safeguard your account credentials, prevent unauthorized access, and notify us immediately of any security breaches.
• Avoid Misuse: Refrain from engaging in prohibited activities as outlined in these Terms.
• Cooperate with Investigations: Fully cooperate with any investigations conducted by Clavis, Striga, or regulatory authorities regarding compliance or misuse of the platform.
  Failure to meet these obligations may result in suspension or termination of your access to our services.

8. Liability and Indemnification

8.1 Scope of Liability

We are liable for:

• Platform accessibility and functionality
• Security of our technical infrastructure
• Proper handling of customer data
• Accurate service information

8.2 Limitation of Liability

Our liability is limited to:

• Direct damages from our negligence
• Excludes consequential losses
• Subject to mandatory law requirements

8.3 Indemnification by Users

You agree to indemnify, defend, and hold harmless Clavis Fintech Solutions Ltd., its affiliates, directors, employees, and partners from and against any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising out of or related to:

• Breach of Terms: Your violation of these Terms and Conditions.
• Misuse of Services: Your misuse or unauthorized use of our platform or services.
• Violation of Laws: Your violation of any applicable laws, regulations, or third-party rights.
• Third-Party Claims: Any claims made by third parties arising from your actions or omissions while using our services.

This indemnification obligation will survive the termination or expiration of these Terms and your use of our services.

9. Changes and Notifications

9.1 Changes to Services

We may modify our services by:

• Providing 30 days' notice for material changes
• Immediate notice for security updates
• Clear communication of impact
• Offering opt-out where appropriate

9.2 Notification Methods

We will notify you through:

• Email communications
• In-app notifications
• Platform announcements
• Website updates

9.3 Acceptance of Updated Terms

By continuing to access or use our services after any updates to these Terms and Conditions, you acknowledge and agree to be bound by the revised Terms. If you do not agree with the updated Terms, you must stop using our services and may request account termination. We will notify you of significant updates via email, in-app notifications, or platform announcements.

10. Governing Law and Jurisdiction

10.1 Applicable Law

These Terms are governed by:

• Laws of the Republic of Estonia
• EU regulations where applicable

10.2 Jurisdiction

Disputes may be resolved in:

• Estonian courts (primary jurisdiction)
• Your local courts where required by law
• Approved alternative dispute resolution bodies

11. Contact Information

For all inquiries:

• Email: support@ozuma.io
• Support Hours: 9 am to 5 pm (EET) [Mon to Friday]

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